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U.S. Res~~~~~~o~c~ ~0~~ c~~

Public Section

December 2018

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Overview ..................................................................................................................................... 1

The Names of Material Entities .................................................................................................. 2

,4 Description of Core Business Lines .......................................................................................... 3

Consolidated or Segment Financial Information Regarding Assets, Liabilities, Capital and

Major Funding Sources ................................................................................................... 3

A Description of Derivative Activities and Hedging Activities .................................................... 7

A List of Memberships in Material Trading, Payment, Clearing and Settlement Systems......... ~

A Description of Foreign Operations .......................................................................................... 8

The Identities of Material Supervisory Authorities .................................................................... 9

The Identities of the Principal Officers ..................................................................................... 10

A Description of the Corporate Governance Structure and Processes Related to Resolution

Planning........................................................................................................................ 12

A Description of Material IVianagement Information Systems ................................................ 13

A Description, at a High Level, of the Covered Company's Resolution Strategy, Covering Such

Items as the Range of Potential Purchasers of the Covered Company, Its Material

Entities and Core Business Lines .................................................................................. 14

For More Information ............................................................................................................... 14

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PUBLIC SECTION

Overview

Industrial and Commercial Bank of China Limited ("ICBC")1 is a commercial bank incorporatedin the People's Republic of China. Through its head office, branches and subsidiaries, ICBCprovided a full range of banking services to customers in 45 countries and regions as of the endof 2017.

Section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act 2(the "Dodd-Frank Act") requires a foreign bank that is a U.S. bank holding company and that has$50 billion or more in total consolidated assets, as determined based on the foreign bank's mostrecent annual report, to develop a resolution plan, commonly known as a "living will." Theresolution plan should describe, hypothetically, the foreign bank's strategy for rapid and orderlyresolution of its operations in the United States in the event of material financial distress orfailure. In November 2011, the Board of Governors of the Federal Reserve System (the "FederalReserve Board") and the Federal Deposit Insurance Corporation (the "FDIC") jointly adopted arule3 (the "Joint Rule") that implements the resolution plan requirement under the Dodd-FrankAct. ICBC is a "covered company" under the Joint Rule. In December 2013, ICBC submittedthe initial resolution plan pursuant to Section 165(d) of the Dodd-Frank Act and the Joint Rule,and ICBC most recently submitted its updated resolution plan in December 2015.4 Thisresolution plan constitutes ICBC's 2018 submission.

This submission is the public portion of the 2018 U.S. resolution plan of ICBC. It describesICBC's U.S. business entities, their lines of business, and ICBC's strategies to resolve them inhypothetical material financial distress or failure in ways that protect the financial stability of theUnited States. ICBC believes a rapid and orderly resolution of ICBC's U.S. operations in suchcircumstance is achievable because, as in the previous years, ICBC engages only in traditionalbanking and securities activities in the United States, and has done so only in a limited way.

Unless otherwise specified, amounts, percentages, and other numerical information in thisresolution plan are estimates. ICBC prepared this plan solely to comply with the Joint Rule andSection 165(d) of Dodd-Frank Act. By its nature, this plan performs analysis based onhypothetical events that are highly unlikely to occur. This plan, therefore, does not, and shouldnot in any way be interpreted to, imply ICBC's assessment or prediction of its or any of itsaffiliates' business conditions.

1 "ICBC" refers to Industrial and Commercial Bank of China Limited either with or without its consolidatedsubsidiaries, as context may require.2 12 U.S.C. § 5365(d)(1).3 76 Fed. Reg. 67323 (Nov. 1, 2011).4 Please see ICBC's 2013 U.S. resolution plan, available at http://www.federalreserve.~ov/bankinfore~/resolution-plans/indl-Comm-bk-of-china-3~-20131231.pdf, and ICBC's 2015 U.S. resolution plan, available athttps://www.federalreserve.~ov/bankinfore~/resolution-plans/indl-comm-bk-of-china-3~-20151231.pdf.

The Names of Material Entities

The Joint Rule requires ICBC to identify its material entities in the United States —those ICBCentities that either carry out ICBC's core business lines or perform certain critical operations. Inthe United States, ICBC maintains a branch, a subsidiary bank, and a company that primarilyoffers settlement and financing services for fixed-income securities. The failure of these entitiesand their business lines would not result in a material loss of revenue or profit to ICBC.Similarly, these entities do not perform any critical operations that would, upon distress orfailure, threaten the financial stability of the United States. For purposes of this resolution plan,however, ICBC considers all three entities as material entities because they collectivelyconstitute, and are significant to, ICBC's U.S. operations. Below is a description of each entity.

Industrial and Commercial Bank of China Limited New York Branch

Industrial and Commercial Bank of China Limited, New York Branch ("ICBC NYBR") is abranch licensed by the New York State Banking Department, a predecessor to the New YorkState Department of Financial Services ("NYDFS"). ICBC NYBR engages in wholesaledeposit-taking, lending, and other banking services primarily for business clients. The branchalso serves as a U.S. dollar clearing center for ICBC and its subsidiary institutions outside theUnited States.s The FDIC does not insure deposits at ICBC NYBR. As a branch, ICBC NYBRis a legal and operational extension of ICBC and is not a separate legal entity.

Industrial and Commercial Bank of China (USA), National Association

Industrial and Commercial Bank of China (USA), National Association ("ICBC USA") is anational bank chartered by the Office of the Comptroller of the Currency (the "OCC"). Itprovides retail and commercial banking services such as deposit-taking, lending, remittances,and settlement. Deposits at ICBC USA are insured by the FDIC. ICBC USA operates threebranches in New York City, five branches in the greater Los Angeles area, five branches in thegreater San Francisco area, and deposit and loan production offices in Seattle, Washington andHouston, Texas. ICBC acquired 80 percent of the shares of common stock of The Bank of EastAsia (U.S.A.) National Association in July 2012 from East Asia Holding Company, Inc.("EAHC"), the U.S. intermediate bank holding company under The Bank of East Asia, Limited("BEA"), a commercial bank organized under Hong Kong law, and then renamed the acquiredbank as "Industrial and Commercial Bank of China (USA), National Association" in November2012. BEA continues to hold the other 20 percent of the shares of common stock of ICBC USAthrough EAHC. ICBC USA understands that EAHC and BEA continue to be treated as bankholding companies in connection with their ownership stake in ICBC USA.

Industrial and Commercial Bank of China Financial Services LLC

Industrial and Commercial Bank of China Financial Services LLC ("ICBC FS") is a broker-dealer registered with the Securities and Exchange Commission (the "SEC") and with securitiesregulators of the states of Alabama, California, Connecticut, Delaware, Florida, Illinois,Missouri, Nebraska, New Jersey, New York, Virginia, and Wisconsin. ICBC FS is also a

5 ICBC's "subsidiary institutions" refer generally to ICBC's branches, subsidiaries (both bank and nonbanlc), offices,and other affiliates.

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member of twelve self-regulatory organizations: the Financial Industry Regulatory Authority("FINRA"), Cboe BYX Exchange, Inc., Cboe BZX Exchange, Inc., Chicago Stock Exchange,Investors' Exchange LLC, NYSE American LLC, NYSE Arca, Inc., NYSE National, Inc.,NASDAQ BX, Inc., NASDAQ PHLX, Inc., NASDAQ Stock Market, and the New York StockExchange. Based in New York City, ICBC FS offers primarily fixed-income securities clearing,settlement and financing services to institutional clients. ICBC FS is a wholly-owned subsidiaryof ICBC.

A Description of Core Business Lines

The Joint Rule requires ICBC to identify its core business lines in the United States. Corebusiness lines are those business lines of a covered company that, in the view of the coveredcompany, upon failure would result in a material loss of revenue, profit, or franchise value. Asnoted above, the failure of the material entities and their business lines would not result in amaterial loss of revenue or profit to ICBC. However, for purposes of resolution planning, ICBCconsiders the following its core business lines in the United States:

Wholesale Banking — ICBC NYBR provides wholesale banl~ing services mostly tobusiness clients with operations in the United States. These services include deposit-taking (forexample, through issuing certificates of deposit), lending (including trade finance and theissuance of letters of credit), U.S. dollar clearing and remittances and Treasury business.

Commercial Banking — ICBC USA provides traditional commercial banking servicessuch as small and medium-size business and retail deposit-taking, lending (including tradefinance and the issuance of letters of credit), remittances, and settlement to both individual andbusiness clients.

Securities Clearing and Financing — ICBC FS provides primarily fixed-income andequity securities clearing and financing services to institutional clients. As a clearing broker,ICBC FS maintains securities accounts for its clients and provides securities clearing andsettlement services. On the financing side, ICBC FS finances a client's need for funds orspecific securities by running a matched book of repurchase agreements ("Repos") and reverseRepos, as we11 as a matched securities lending book. Almost all collateral underlying ICBC FS'sRepos and reverse Repos is composed of U.S. Treasury and Agency securities. On the securitieslending side, almost all collateral underlying the transactions is composed of U.S. equities.ICBC FS does not trade securities on a proprietary basis.

Consolidated or Segment Financial Information Regarding Assets, Liabilities, Capital andMajor Funding Sources

ICBC's summary financial information and capital ratios as of the end of 2017 and 2016 are setforth in the tables below. The information was prepared in accordance with the InternationalFinancial Reporting Standards ("IFRS").

Table 1 ICBC Consolidated Balance Sheets6

In ~ million

Dec. 31, 2017 Dec. 31, 2016

ASSETS

Cash and balances with central banks 3,613,872 3,350,788

Due from banks and other financial institutions 847,611 797,473

Financial assets held for trading 87,337 189,331

Financial assets designated at fair value through profit or loss 353,601 285,144

Derivative financial assets 89,013 94,452

Reverse repurchase agreements 986,631 755,627

Loans and advances to customers 13,892,966 12,767,334

Financial investments 5,315,766 5,006,699

Investments in associates and joint ventures 32,441 30,077

Property and equipment 247,744 246,209

Deferred income tax assets 48,392 28,398

Other assets 571,669 585,733

TOTAL ASSETS 26,087,043 24,137,265

LIABILITIES

Due to central banks 456 545

Financial liabilities designated at fair value through profifi or loss 425,948 366,752

Derivative financial liabilities 78,556 89,960

Due to banks and other financial institutions 1,706,549 2,016,799

Repurchase agreements 1,046,338 589,306

Certificates of deposit 260,274 218,427

Due to customers 19,226,349 17,825,302

Income tax payable ~ 70,644 52,640

Deferred income tax liabilities 433 604

Debt securities issued 526,940 357,937

Other liabilities 603,500 637,830

TOTAL LIABILITIES 23,945,987 22,156,102

EQUITY

Equity attributable to equity holders of the parent company

Share capital 356,407 356,407

Other equity instruments - 86,051 86,051

Reserves 587,489 586,630

Retained profits 1,097,544 940,663

2,127,491 1,969,751

Non-controlling interests 13,565 11,412

TOTAL EQUITY 2,141,056 1,981,163

TOTAL EQUITY AND LIABILITIES 26,087,043 24,137,265

6 Please see ICBC's 2017 annual report, available athttp://v.icbc.com.cn/userfiles/Resources/ICBCLTD/download/2018/720180423.pdf, for additional information.

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Table 2 — ICBC Risk-Weighted Assets and Capital Adequacy Ratios

In ~ million, except ratios

Dec. 31, 2017 Dec. 31, 2016

Risk-weighted assets 15,902,801 14,564,617

Core tier 1 capital adequacy ratio 12.77% 12.87%

Tier 1 capital adequacy ratio 13.27% 13.42%

Capital adequacy ratio 15.14% 14.61%

1 CBC NYBR

As of December 31, 2017, ICBC NYBR had approximately $28 billion g in total assets,

approximately $11.7 billion of which were placed with the Federal Reserve Bank of New York

(the "FRBNY"). As of the same date, ICBC NYBR had approximately $28 billion in totalliabilities, with $22.5 billion in liabilities to non-related parties (of which $10.7 billion weredeposits and credit balances and $7.9 billion were other borrowed money) and $5.5 billion werenet amounts due to ICBC NYBR's related depository institutions, which are primarily non-U.S.affiliates of ICBC.9

As a branch, ICBC NYBR is a legal and operational extension of ICBC and not a separatelycapitalized legal entity. ICBC NYBR therefore does not maintain its own capital.

1 CBC USA

As of December 31, 2017, ICBC USA had $2.36 billion in total assets, $2.04 billion of whichwere loans and leases. As of the same date, ICBC USA had $2.02 billion in total liabilities,$1.99 billion of which were deposits.

ICBC owns 80 percent of the shares of common stock of ICBC USA. As of December 31, 2017,ICBC USA had $334 million in total equity capital. ICBC USA's common equity tier 1 capitaladequacy ratio, tier 1 capital adequacy ratio and total capital adequacy ratio as of the same datewere 13.6 percent, 13.6 percent and 14.2 percent, respectively.lo

These ratios were calculated in accordance with the Regulation Governing Capital of Commercial Banlcs(Provisional) promulgated by the China Banking Regulatory Cormnission (now the China Banking and InsuranceRegulatory Commission) in June 2012 (the "Capital Re ulg ation"). See the Decree of the CBRC, No. 1, 2012,available at http://www.cbrc.Gov.cn/En~docView.do?docID=86EC2D338BB24111B3AC5D7C5C4F1B28. The CapitalRegulation represents the CBRC's implementation of Basel III and came into effect on January 1, 2013.Commercial banks in China, including ICBC, must achieve full compliance with the Capital Regulation by 2018.8 In accordance with FFIEC instructions, ICBC NYBR reports amounts due to/from related depository institutionson a net basis.9 For more information, please see ICBC NYBR's FFIEC 002 —Report of Assets and Liabilities dated December31, 2017, available at http://www.ffiec.Gov/nicpubweb/nicweb/SearchForm.aspx?pS=2.to For more information, please see ICBC USA's FFIEC 041 —Consolidated Reports of Condition and Incomedated December 31, 2017, available at https://cdr.ffiec.gov/public/Mana~eFacsimiles.aspx.

ICBC FS

As of December 31, 2017, ICBC FS had $31.9 billion in total assets, approximately $21 billionof which were U.S. Government and Agency securities purchased under reverse Repos andapproximately $7.3 billion in securities borrowed, consisting of U.S. equities and U.S.Government securities. As of the same date, ICBC FS had $31.3 billion in liabilities, $23.9billion of which were securities sold under Repos and approximately X4,1 billion of which weresecurities loaned. ICBC FS faces limited credit risks and market risks because it closely matchesits Repos with reverses Repos and also matches its securities borrowings with securities loans.

ICBC FS is a wholly-owned subsidiary of ICBC. As of December 31, 2017, ICBC FS had $154million in equity capital and $400 million in subordinated debt held by ICBC.

ICBC FS is subject to the minimum net capital requirement imposed by the SEC's Uniform NetCapital Rule 15c3-1. Under the "alternative method" elected, ICBC FS must maintain minimumnet capital equal to the greater of $1.5 million or 2% of "aggregate debit items," which aregenerally ICBC FS's receivables from (or incurred as principal on behalf o~ its customers. Asof December 31, 2017, ICBC FS had net capital of $484.4 million, which was about $472.6million in excess of the minimum net capital requirement.

Funding Sources

ICBC NYBR is funded primarily by deposits made by ICBC's Head Office (the "Head Office"),wholesale deposits in the form of large-denomination certificates of deposits ("CDs") and clientdeposits, medium-term notes ("MTNs") and commercial paper ("CP") issued, Fed Fundsborrowing and other deposits by ICBC and its non-U.S. affiliates. Typical purchasers of theCDs, MTNs and CP, as well as the lenders of Fed Funds to ICBC NYBR, are other financialinstitutions or other institutional investors. If needed, ICBC NYBR also has access to committedcredit facilities offered by certain unaffiliated banks and liquidity support by ICBC's HeadOffice. ICBC NYBR can also access contingency funding through the Federal Reserve BankDiscount ~1Vindow offered by the FRBNY.

ICBC USA is funded primarily by retail deposits. Typical depositors at ICBC USA areindividuals and small-to-medium sized companies. If needed, ICBC USA can accesscontingency funding through a revolving credit facility offered by its shareholders or through theFederal Reserve Bank Discount Window offered by the FRBNY, to which ICBC USA haspledged collateral to support borrowings. ICBC USA has also pledged collateral to the FederalHome Loan Bank of New York to enable it to borrow from that institution if needed.

ICBC FS is funded primarily by selling, or "repoing out," U.S. Government securities andAgency securities under Repos. Typical counterparties in these Repos are other broker-dealersand other financial institutions. ICBC FS has also borrowed from ICBC a total of $400 millionon a subordinated basis under two subordinated borrowing agreements as operating funds. ICBCFS is also funded by certain credit facilities provided by ICBC NYBR. ICBC FS also has acommitted line of credit arrangement with ICBC NYBR in the amount of $250 million, althoughthere were no borrowings outstanding under that facility during 2017 and as of the end of thatyear.

A Description of Derivative Activities and Hedging Activities

Derivatives are financial instruments that derive their values from other financial items. Whilederivatives could be purchased and sold for profit, the material entities use derivatives only tomitigate risks.

None of the material entities had any material hedges as of December 31, 2017.

Like other depository institutions, however, ICBC NYBR faces certain risks attributable tomarket interest rate fluctuations in the ordinary course of business. Consequently, ICBC NYBRmay from time to time enter into interest rate swaps in which it exchanges fixed rates generatedby its assets for floating rates, thereby effectively converting its fixed-rate assets to floating-rateassets, or in which ICBC NYBR makes the opposite exchange. Similar interest rate risk hedgingor mitigating strategies may be used on the liabilities side. ICBC NYBR would record interestrate swaps at fair values estimated as the settlement prices of hypothetical reverse swaps thatwould cancel the interest rate swaps purchased.

ICBC USA had no interest rate swaps or other derivatives outstanding as of December 31, 2017and has not entered into any such transactions during 2018. However, ICBC USA could enterinto interest rate swaps from time to time in order to hedge the increased cost of funding fixed-rate loans using variable rate deposits during periods of increasing market interest rates.

As abroker-dealer, ICBC FS faces primarily the risks that its counterparties would default onsecurities transactions. ICBC FS mitigates such risks by entering into a significant volume of itssecurities transactions with a central counterparty that distributes risks across a large number ofmarket participants, as well as carefully screening its counterparties through its Credit Riskreview process. ICBC FS trades Repos and reverse Repos and enters into securities borrowingand lending transactions in the ordinary course of business, and it faces limited market riskbecause it closely matches its Repos with reverses Repos and also matches its securitiesborrowings with securities loans. ICBC FS records Repos and reverse Repos as well assecurities borrowings and securities loans as collateralized financing transactions at theircontracted resale or repurchase amounts. These contracted amounts approximate fair valuebecause of the short-term nature of these transactions and the high liquidity of the underlyingcollateral.

A List of Memberships in Material Trading, Payment, Clearing and Settlement Systems

Table 3 —Memberships in Material Trading, Payment, Clearing and Settlement Systems

System Names System Types Material Entities

Fedwire Funds Service Payment ICBC NYBR, ICBC USA

Clearing House Interbank Payments System Payment ICBC NYBR

Society for Worldwide Interbank Financial

TelecommunicationCommunication ICBC NYBR, ICBC USA

Visa Payment ICBC USA

Unionpay International Payment ICBC USA

STAR Network Payment ICBC USA

The Depository Trust Company Settlement, Clearing ICBC FS

Fixed Income Clearing Corporation Settlement, Clearing ICBC FS

National Securities Clearing Corporation Settlement, Clearing ICBC FS

Options Clearing Corporation Settlement, Clearing ICBC FS

A Description of Foreign Operations

With a presence on six continents and overseas operations in 45 countries and regions at the endof 2017, ICBC provided comprehensive financial services to approximately 6.3 million corporatecustomers and 567 million individual customers through its networ~~ of approximately 16,469institutions in China, 419 institutions outside China, and 1,545 correspondent banks worldwide.

ICBC provided the following key product lines to its customers as of the end of 2017:

Corporate Banking — ICBC provided 6.3 million corporate customers with a full range ofbanking solutions such as corporate deposit taking, lending (including trade finance and theissuance of letters of credit), settlement and remittances, and investment banking.

Personal Banking — ICBC provided 567 million individual customers withcomprehensive services such as retail deposit taking, lending, wealth management, privatebanking, and bank card products.

The table below sets forth ICBC's assets and profits outside China by geographical areas.

s

Table 4 — ICBC Assets and Profits Outside China

In $million

Assets Profits before TaxGeographic Areas Dec. 31 2017 Dec. 31 2016 2017 2016Hong Kong and Macau 178,045 159,445 1,850 1,646Asia-Pacific Region* 84,346 69,935 783 567Europe 69,933 58,317 273 140America 66,745 64,723 586 582Africa RepresentativeOffice

Eliminations (44,757) (49,741) - -

Subtotal 354,312 302,679 3,492 2,935Investment in StandardBank Group Limited" 4,285 3,771 426 312

Total 358,597 306,450 3,918 3,247

* Except Hong Kong and Macau•'`*A listed commercial bank in the Republic of South Africa.

The Identities of Material Supervisory Authorities

ICBC's operations are supervised and regulated by authorities in each of the jurisdiction where itconducts businesses. Central banks, bank supervisors, financial services regulators, securitiesregulators, and self-regulatory organizations are among the authorities that supervise ICBC.

ICBC has material operations only in China. ICBC identifies in the table below the Chinesesupervisory authorities that it considers as material.

Table 5 —Material Supervisory Authorities in China

Supervisory Authorities Scopes of SupervisionChina Banking and Insurance Regulatory Commission The CBIRC is China's primary bank and insurance(the "CBIRC") supervisor and regulator. It is responsible for the

comprehensive consolidated supervision of Chinesebanking and organizations as well as the assurancebusiness and insurance activities of banks in China.The CB1RC was established in April 2018 by a mergerof the former China Banking Regulatory Commissionand the former China Insurance RegulatoryCommission.

People's Bank of China (the "PBOC") The PBOC is China's central bank and primarysupervisor for anti-money laundering matters. Itregulates interbank lending and bond markets, and,together with the CBIRC and the CSRC, enforcesChina's anti-money laundering laws and regulations.

State Administration of Foreign Exchange ("SAFE") SAFE regulates Chinese banks' foreign exchange andsettlement transactions.

China Securities Regulatory Commission (the "CSRC") The CSRC is China's primary securities regulator. It isresponsible for the oversight of publicly tradedcompanies and securities markets and the provisionof custody services to investment funds.

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The material entities in the United States are subject to federal, state, and industry specificsupervision and regulations. ICBC identifies in the table below material authorities in the UnitedStates that supervise the material entities.

Table 6 —Material Supervisory Authorities in the United States

Material Entities Material Supervisory Authoritiesll

ICBC NYBR Federal Reserve Board, NYDFS

ICBC USA

ICBC FS

The Identities of the Principal Officers

Federal Reserve Board, OCC, FDIC

Federal Reserve Board, SEC, FINRA

The tables below set forth the directors and principal officers of ICBC and of the material entitiesin the United States.

Table 7—Directors and Principal Officers of ICBC

Names Titles with ICBC

Executive Directors

YI Huffman

GU Shu

Non-Executive Directors

CHENG Fengchao

ZHENG Fuqing

MEI Yingchun

DONG Shi

YE Donghai

Independent Non-Executive Directors

HONG Yongmiao

Anthony Francis NEOH

YANG Siu Shun

Sheila Colleen BAIR

SHEN Si

Nout WELLINK

Members of the Board of Supervisors12

ZHANG Wei

HUI Ping

HUANG Li

QU Qiang

SHEN Bingxi

Chairman of the Board of Directors, Executive DirectorPresident of ICBC, Vice Chairman of the Board of Directors,Executive Director

Non-Executive Director

Non-Executive Director

Non-Executive Director

Non-Executive Director

Non-Executive Director

Independent Non-Executive Director

Independent Non-Executive Director

Independent Non-Executive Director

Independent Non-Executive Director

Independent Non-Executive Director

Independent Non-Executive Director

Shareholder Supervisor

Employee Supervisor

Employee Supervisor

External Supervisor

External Supervisor

11 The Federal Reserve Board supervises ICBC USA and ICBC FS as part of its consolidated supervision of ICBC'sU.S. operations.12 Under Chinese corporate law, the board of supervisors is a governing board responsible for the oversight of thefiscal and financial activities of a company, including the selection of the outside auditor, the preparation andapproval of the company's audited financial statements, and supervision of the development and implementation ofthe company's fiscal, risk management and internal control policies.

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Names Titles with ICBC

Principal OfficersGU Shu PresidentWANG Lin Secretary of the Party Discipline CommitteeHU Hao Senior Executive Vice President

TAN Jiong Senior Executive Vice President

WANG Bairong Chief Risk Officer

GUAN Xuegin~ Board Secretary

Table 8 Principal Officers of IC~C NYBR

fVames Titles with IC~C NYBR

Senior Management

XIAO Yuqiang General Manager

SUN Guoshen Deputy General Manager

HE Zili Deputy General Manager

LYU Yu Deputy General Manager

GUO Xinyue Deputy General Manager

Frank MORISANO Chief Risl< Officer

Paul HASH Chief Comaliance Officer

Table 9 Directors and Principal Officers of ICBC (JSA

Names Titles with IC~C IJSA

Non-Executive Directors

XIAO Yuqiang

LIN Qingsheng

Peter YUEN

Executive Directors

ZHANG Jianyu

David WILLNER

Independent Non-Executive Directors

Mary Wadsworth DARBY

Sara JUDGE

Joel EPSTEIN*

Karen Elliott HOUSE

Senior Management

ZHANG Jianyu

David WILLNER

HE Zili

LU Yuan

I<APVG Jiande

Chairman of the Board, Non-executive DirectorNon-executive Director

Non-executive Director

Executive Director

Executive Director

Independent Non-executive DirectorIndependent Non-executive DirectorIndependent Non-executive DirectorIndependent Non-executive Director

President and Chief Executive OfficerDeputy Chief Executive OfficerDeputy Chief Executive OfficerDeputy Chief Executive OfficerAssistant Chief Executive Officer and Head of Market West Coast

* Mr. Epstein became a member of the Board of Directors of ICBC USA in October 2018'

Table 10 —Managers and Principal Officers of ICBC FS

Names Titles with ICBC FS

Managers

XIAO Yuqiang Chairman of the Board of Managers

ZHANG Weiliang Manager, Board of Managers

Senior Management

XING Yinghua Chief Executive Officer and Manager

LU Yi Executive Managing Director

Donato Peter FERONE Chief Operating Officer

Frederick Gerard FERRARO Chief Financial Officer

Alan Brad LEVY Chief Commercial Officer

Paul MAY Chief Compliance Officer

A Description of the Corporate Governance Structure and Processes Related to Resolution

Planning

ICBC utilizes its enterprise risk management system to develop and maintain this resolutionplan.13 The system consists of three organizational levels, each responsible for a different phaseof the development and maintenance of this resolution plan.

Board of Directors Level — ICBC's Board of Directors is the top-tier governance body ofICBC. It is ultimately responsible for the safety and soundness of ICBC's daily operations on aglobal basis. The Board of Directors provides high-level guidance and approves or authorizes adelegate to approve each submission of the resolution plan.

Head Office Level — ICBC Head Office's Risk Management Committee and RiskManagement Department work closely with Risk Management Departments of ICBC'ssubsidiary institutions, including the material entities. They review the resolution plan andprovide comments as needed.

Material Entity Level — As part of the "Subsidiary Level" of resolution planning forICBC's worldwide subsidiary institutions, the Material Entity Level consists of the seniormanagement and risk management personnel of ICBC's material entities. The managementteams of ICBC's material entities formulated the specifics of the U.S. resolution strategies inconsultation with professionals from business areas, such as trading and banking desks, andsupport functions, such as information technology and accounting. External and internal counselwere also engaged to develop the legal elements of ICBC's U.S. resolution strategies.

Development Procedures of ICBC's 2018 U.S. Resolution Plan

This plan constitutes ICBC's submission for 2018 of its U.S. resolution plan. As in the case ofICBC's most recent resolution plan submission, the plan's development was coordinated at theMaterial Entity Level. The Head Office Level provided input and the President of ICBC

13 please refer to page 47 of ICBC's 2017 annual report for more information about the enterprise risk managementsystem.

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approved this annual submission as the expressly authorized delegate of ICBC's Board ofDirectors.

Maintenance Procedures of Subsequent Resolution Plans

Regular Maintenance — ICBC will review and revise its U.S. resolution plan as requiredby the Federal Reserve Board and the FDIC. Maintenance will begin with a survey of changes atmaterial entities and developments in applicable laws and regulations. The survey will alsoinclude the consideration of whether new material entities need to be added to the plan. TheMaterial Entity Level will update this resolution plan based on the survey results, incorporateany comments received from the Head Office Level, and seek approval for submission from thedelegate expressly authorized by the Board of Directors Level.

Special Maintenance —The material entities will notify the Federal Reserve Board andthe FDIC within 45 days of the occurrence of any event that has a material effect on thisresolution plan. Concurrently, management teams of the material entities will update thisresolution plan accordingly. The Head Office Level will review the update made and, if theupdate is material, seek approval from the delegate expressly authorized by Board of Directorsbefore submitting the updated resolution plan.

A Description of Material Management Information Systems

ICBC recognizes information technology as a key area of competitiveness. ICBC has investedsignificantly annually on system maintenance and innovation. ICBC operates some of the mostadvanced and dependable information systems among commercial banks in China, and itmaintains a large team of IT professionals.

The material entities utilize management information systems to support their daily operations,regulatory reporting, and decision making. ICBC NYBR and ICBC USA utilize systemsdeveloped by ICBC as well as third-party vendors. To improve service reliability andconsistency, ICBC USA has transitioned from avendor-supplied core banking system to theproprietary system that ICBC has developed internally. ICBC FS continues to rely on systemsused by it before the company was acquired by ICBC.

All material management information systems used by the material entities are capable ofgenerating reports for management and regulators either upon demand or as scheduled. ICBChas also established procedures to facilitate regulatory access to these systems in times of crisis.

The material entities are prepared for the disruption of material management informationsystems. Data stored are regularly backed up by different means and at different locations, andbusiness continuity plans are in place. Material entities that utilize internal systems are furtherprotected by the multiple layers of redundancy offered by ICBC's state-of-the-art data centers inChina.

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A Description, at a High Level, of the Covered Company's Resolution Strategy, CoveringSuch Items as the Range of Potential Purchasers of the Covered Company, Its MaterialEntities and Core Business Lines

ICBC designs resolution strategies for its U.S. operations under the baseline, adverse andseverely adverse scenarios respectively.l`~ For purposes of this 2018 resolution plan, however,ICBC has assumed that the material financial distress or failure of the material entities occursunder the severely adverse scenario, as directed by the Federal Reserve Board and the FDIC inthe joint letter dated January 29, 2018 to ICBC regarding ICBC's submission of a "ReducedPlan" as its resolution plan submission for 2018 and for each of the following two dates bywhich ICBC is required to submit a resolution plan (the "2018 Joint Letter"). is The 2018 JointLetter further states that ICBC's Reduced Plans are exempt from the requirement to considerbaseline or adverse economic conditions.

If material financial distress occurs under the severely adverse scenario, which requires ICBC toassume a severe global recession, the material entities would likely immediately pursueresolution under the applicable liquidation or insolvency regime after determining that parentliquidity support would be unavailable and recoveries unlikely.

The resolution strategies designed by ICBC for the material entities do not anticipategovernmental bail-outs.

For More Information

ICBC's 2017 annual report contains additional information about ICBC's global operations,financial conditions, management structure, and more. It is available athttp://v.icbc.com.cn/userfiles/Resources/ICBCLTD/download/2018/720180423.pdf.

ICBC NYBR and ICBC USA periodically submit financial statements to the Federal FinancialInstitutions Examination Council (the "FFIEC"). These reports are available for ICBC NYBRfrom the Federal Reserve Board's National Information Center website athttps://www.ffiec.Gov/nicpubweb/nicweb/SearchForm.aspx?pS=2 and for ICBC USA from theFFIEC's Central Data Repository at https://cdr.ffiec.~ov/public.

ICBC FS periodically reports its financial and operational results to the SEC. These reports areavailable from the SEC's Electronic Data Gathering, Analysis, and Retrieval system athttps://www.sec. ov/ed~ar/searched arg /companysearch.html. Additional information aboutICBC FS and certain of its securities professionals are available from FINRA's BrokerChecktool at http://brokercheck.finra.or~.

1`~ See Federal Reserve Board, 2018 Supervisory Scenarios for Annual Stress Tests Required under the Dodd-FranlcAct Stress Testing Rules and the Capital Plan Rule (Feb. 1, 2018), available athops://www.federalreserve.Gov/newsevents/pressreleases/files/bcre~20180201 al .pdf.is Letter from Michael S. Gibson, Federal Reserve Board, and Doreen R. Eberley, FDIC, to Vito Ferrara, ICBC(Jan. 29, 2018), available at https://www.federalreserve.~ov/newsevents/pressreleases/files/bcre~20180129a1 l.~df.

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INDEX OF TABLES

Table 1— ICBC Consolidated Balance Sheets

Table 2 — ICBC Risk-Weighted Assets and Capital Adequacy Ratios

Table 3 —Memberships in Material Trading, Payment, Clearing and Settlement Systems

Table 4— ICBC Assets and Profits Outside China

Table 5 —Material Supervisory Authorities in China

Table 6—Material Supervisory Authorities in the United States

Table 7—Directorsand Principal Officers of ICBC

Table 8 —Principal Officers of ICBC NYBR

Table 9 Directors and Principal Officers of ICBC USA

Table 10—Managers and Principal Officers of ICBC FS

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Industrial and Commercial Banl< ofChina Limited, IVew Yorl< Branch

Industrial and Commercial Banl< ofChina (USA) IV.A.

Industrial and Commercial ~anl<of China Financial Services, LLC

725 Fifth Avenue 1633 Broadway, 28t" Floor 1633 Broadway, 2~t" FloorfVew Yorl<, fVY 10022 New York, i~Y 10019 New York, RlY 10019